SIVAKUMARAN PUGAZHENDHI,CHENNAI vs. PCIT,, CHENNAI-4

In the result, the appeal of the assessee is allowed

Bench: Shri Mahavir Singhand Shri Manoj Kumar Aggarwalआयकर अपील सं./Ita No.27/Chny/2022 िनधा"रण वष" /Assessment Year: 2014-15 Sivakumaran Pugazhendhi, The Principal Commissioner 70 Raja Agraharam Street, Vs. Of Income Tax, Poonamalle, Chennai-4. Chennai – 600 056. [Pan: Aiapp-7309-R] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Ms. T.V. Muthu Abirami, Advocate ""यथ" क" ओर से /Respondent By : Shri M. Rajan, Cit सुनवाई क" तारीख/Date Of Hearing : 05.09.2022 : 21.09.2022 घोषणा क" तारीख /Date Of Pronouncement आदेश / O R D E R

Reassessment completed u/s. 143(3) r/w. s. 147 of the Act 21.09.2021 Revision notice u/s. 263 of the Act was issued by PCIT 18.11.2021 Revision order passed by PCIT u/s. 263 of the Act 11. On a careful reading of the impugned revision order of PCIT passed under section 263 of the Act, it becomes very much clear that

THE GATE OF HOPE CHARITABLE TRUST,CHENNAI vs. ITO (EXEMPTIONS) WARD-2,, CHENNAI

The appeals of the assessee are allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

1,00,18,456/-, the assessee has applied a sum of Rs. 90,66,711/ , the assessee has applied a sum of Rs. 90,66,711/ , the assessee has applied a sum of Rs. 90,66,711/- towards the above said projects, which are claimed as charitable towards the above said projects, which are claimed as charitable towards the above

THE GATE OF HOPE CHARITABLE TRUST,,CHENNAI vs. ITO(E), WARD-2,, CHENNAI

The appeals of the assessee are allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

1,00,18,456/-, the assessee has applied a sum of Rs. 90,66,711/ , the assessee has applied a sum of Rs. 90,66,711/ , the assessee has applied a sum of Rs. 90,66,711/- towards the above said projects, which are claimed as charitable towards the above said projects, which are claimed as charitable towards the above

MEGNANAPURAM PACCS,TIRUCHENDUR vs. PCIT,, MADURAI

reassessment. Since the\nreassessment had been set aside, the order of the Tribunal cancelling the penalty\nlevied under section 271(1) (c) of the Act was also legal. \" (p. 787)\n7. Addl. CIT v. Badri Prasad Kashi Prasad [1993] 200 ITR 206 (All.) \"Held, that the\nlevy of penalty was based on the addition to income made by the Income

SRI K.SRIKANTH,,CHENNAI vs. ACIT,, CHENNAI

In the result, all the four appeals adjudicated by us in this order are partly allowed

Bench: Shri George Mathan & Shri Ramit Kochar

147 of the 1961 Act , vide reassessment order dated 31.12.2008 is erroneous so far as prejudicial to the interest of Revenue for reasons stated therein in the revisionary order. The appeal in ITA no. 1016/chny/2012 is filed by assessee for ay: 2001-02 which has arisen from appellate order dated 27.03.2012 passed by learned CIT(A) , which appeal has arisen

SHRI K.SRIKANTH,CHENNAI vs. ACIT, CHENNAI

In the result, all the four appeals adjudicated by us in this order are partly allowed

Bench: Shri George Mathan & Shri Ramit Kochar

147 of the 1961 Act , vide reassessment order dated 31.12.2008 is erroneous so far as prejudicial to the interest of Revenue for reasons stated therein in the revisionary order. The appeal in ITA no. 1016/chny/2012 is filed by assessee for ay: 2001-02 which has arisen from appellate order dated 27.03.2012 passed by learned CIT(A) , which appeal has arisen

ACIT,, CHENNAI vs. SRI. K.SRIKANTH,, CHENNAI

In the result, all the four appeals adjudicated by us in this order are partly allowed

Bench: Shri George Mathan & Shri Ramit Kochar

147 of the 1961 Act , vide reassessment order dated 31.12.2008 is erroneous so far as prejudicial to the interest of Revenue for reasons stated therein in the revisionary order. The appeal in ITA no. 1016/chny/2012 is filed by assessee for ay: 2001-02 which has arisen from appellate order dated 27.03.2012 passed by learned CIT(A) , which appeal has arisen

SRI K.SRIKANTH,,CHENNAI vs. ACIT,, CHENNAI

In the result, all the four appeals adjudicated by us in this order are partly allowed

Bench: Shri George Mathan & Shri Ramit Kochar

147 of the 1961 Act , vide reassessment order dated 31.12.2008 is erroneous so far as prejudicial to the interest of Revenue for reasons stated therein in the revisionary order. The appeal in ITA no. 1016/chny/2012 is filed by assessee for ay: 2001-02 which has arisen from appellate order dated 27.03.2012 passed by learned CIT(A) , which appeal has arisen

ALTHI VENKATA NARENDRA RAJU,CHENNAI vs. DCIT, CENTRAL CIRCLE-1(2), CHENNAI

In the result, the appeal filed by the assessee in ITA No

263,\nor section 264 or in an order of any court in a proceeding otherwise than by way of\nappeal or reference under this Act, on or before the expiry of twelve months from the\nend of the month in which such order is received or passed by the 30[Principal Chief\nCommissioner or Chief Commissioner or] Principal Commissioner\nCommissioner

S.VIJAYALAKSHMI ,PUDUCHERRY vs. ITO WARD I(2) , PONDICHERRY

In the result, the appeals of the assessee for assessment

Bench: Shri Chandra Poojari & Shri George Mathan

263 vide order dt.28.03.2012 directing the Assessing Office to redo the assessment de-novo after taking into judicial pronouncements on the issue of estimation of CPWD rates and the deduction for self- supervision and other contentions raised by the assessee. In obedience to the said order of the learned Commissioner, the ld. Assessing Officer issued notice u/s

S.VIJAYALAKSHMI ,PUDUCHERRY vs. ITO WARD I(2) , PONDICHERRY

In the result, the appeals of the assessee for assessment

Bench: Shri Chandra Poojari & Shri George Mathan

263 vide order dt.28.03.2012 directing the Assessing Office to redo the assessment de-novo after taking into judicial pronouncements on the issue of estimation of CPWD rates and the deduction for self- supervision and other contentions raised by the assessee. In obedience to the said order of the learned Commissioner, the ld. Assessing Officer issued notice u/s

S.VIJAYALAKSHMI ,PUDUCHERRY vs. ITO WARD I(2) , PONDICHERRY

In the result, the appeals of the assessee for assessment

Bench: Shri Chandra Poojari & Shri George Mathan

263 vide order dt.28.03.2012 directing the Assessing Office to redo the assessment de-novo after taking into judicial pronouncements on the issue of estimation of CPWD rates and the deduction for self- supervision and other contentions raised by the assessee. In obedience to the said order of the learned Commissioner, the ld. Assessing Officer issued notice u/s

S.VIJAYALAKSHMI ,PUDUCHERRY vs. ITO WARD I(2) , PONDICHERRY

In the result, the appeals of the assessee for assessment

Bench: Shri Chandra Poojari & Shri George Mathan

263 vide order dt.28.03.2012 directing the Assessing Office to redo the assessment de-novo after taking into judicial pronouncements on the issue of estimation of CPWD rates and the deduction for self- supervision and other contentions raised by the assessee. In obedience to the said order of the learned Commissioner, the ld. Assessing Officer issued notice u/s

KELLER (M) SDN BHD,CHENNAI vs. DCIT INTL TAX 1(2), CHENNAI, CHENNAI

In the result, the appeal of the assessee stands allowed

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.1319/Chny/2023 (िनधा"रणवष" / Assessment Year: 2018-2019) Vs. The Deputy Commissioner Of Keller (M) Sdn Bhd, Income Tax, 7Th Floor, Centennial Square, International Taxation 1(2) No.6A, Dr. Ambedkar Road, Chennai. Kodambakkam, Chennai 600 024. [Pan: Aagck 8014M] (अपीलाथ"/Appellant) (""यथ"/Respondent) अपीलाथ" क" ओर से/ Appellant By : Shri. Ashik Shah, C.A. ""यथ" क" ओर से /Respondent By : Shri. Nilay Baran Som, Irs, Cit.

Reassessment proceedings under Section 148 of the Act 4 31-Mar 23 Notice under section 148 of the Act 5 28-Apr 23 Income tax return filed in response to notice under section 148 09- June 22 (a) Notice under section 142(1) of the to 18 Oct Act dated 09-Jun-22 and 07-Oct-22 were 22 issued

SHRI R PANNERSELVAM,,CHENNAI vs. DCIT, CC-3(3),, CHENNAI

In the result, the appeal filed by the assessee is allowed

Bench: Shri Mahavir Singhand Shri Girish Agrawal

Reassessment Order dated 03.06.93 passed u/s. 143(3) r.w.s. 147 of the Act especially when the original assessment order passed u/s. 143(3) of the Act on 15.12.1989 was cancelled by C.I.T. Amritsar vide his order dated 28.02.92 passed u/s. 263 of the Act and no fresh order was passed pursuant thereto. Therefore, the question no. 1 is answered

INTERNATIONAL SEAPORT DREDGING PRIVATE LIMITED,CHENNAI vs. PCIT - 1, CHENNAI

In the result, the appeal of the assessee is allowed

Bench: HON’BLE SHRI MANOJ KUMAR AGGARWAL, AM AND HON’BLE SHRI MANU KUMAR GIRI (Judicial Member)

1) (2) (3) (4) i 2016-17 ii 2013-14 14491494 14491494 iii 2012-13 148847374 148847374 iv 2010-11 270130659 270130659 v 2009-10 164803652 164803652 vi Total 598273179 598273179 ii. Facts and figures and issues recorded in ‘Reasons for reopening u/s 147’ (para 3 supra) is similar as observed by the ld.CIT in his notice u/s 263

SANTECH SOLUTONS PVT LIMITED,CHENNAI vs. DCIT, CHENNAI

In the result, the appeal of the assessee is treated as 9

Bench: Shri Abraham P.George & Shri George Mathanआयकर अपील सं./I.T.A. No.1036/Mds/2016 "नधा"रण वष" /Assessment Year : 2008-2009

u/s 148 was issued’’. During the course of assessment proceedings, assessee had filed a letter dated 12.11.2010 which stated as under:- Date: 12/11/2010 To The Assistant Commissioner of Income Tax Company Circle VI(I), Chennai - 34 Sub:!T Assessment - AY 08-09 Ref Notice u/s.143(2) dated 12.08.2009 Dear Sir, Further to our appearance before your goodself

M/S. ASHOK LEYLAND LTD.,CHENNAI vs. DCIT, NCC-8(1), LTU-II,, CHENNAI

In the result, appeal filed by the assessee is allowed

Bench: Shri Aby T. Varkey & Shri Jagadish

1 to Section 147 is not applicable in the present case. 4. Referring to the first proviso to Section 147 of the Act, the Ld. AR submitted that, where an assessee had filed a return of income and thereafter the assessment was completed either under section 143(3) or under section 147 of the Act, then in such case